For further information, please contact: CORRUPTION ... PREVENTION... · For further information, please contact: ... Public Procurement and Asset Disposal Act 2015 ... Use PPAD,

For further information, please contact:

Head Office The Chief Executive Officer/Secretary

Pest Control Products Board Off Waiyaki Way, Loresho

P. O. Box 13794 - 00800 Nairobi, Kenya. Tel.: 254-020-8021846/7/8

Mobile: 0720480904/0735778743 Email: [email protected]/

[email protected] Website: www.pcpb.or.ke

PEST CONTROL PRODUCTS BOARD [A Statutory Organization of the Kenya Government]

CORRUPTION PREVENTION PLAN

VISION

To be a world class regulatory agency for pest control products.

Revised 2016

PCPB CORRUPTION PREVENTION PLAN Page 2

MISSION To provide professional, efficient and effective regulatory service for trade, safe use and disposal of pest control products while ensuring safety to humans, animals and the environment.


REGIONAL OFFICES Coast Regional Office The Regional Manager

KARLO Mtwapa, P.O. Box 10636 - 80101

Bamburi, Kenya. Tel: 254-020-2375522.

Email: [email protected]

Western Regional Office The Regional Manager

MURBS Building P.O. Box 2757 - 40100

Kisumu, Kenya. Tel: 254-020-8068933


Mt. Kenya Regional Office The Regional Manager

Embu Motors Plaza P.O. Box 2754 - 60100

Embu, Kenya. Tel: 254-068-31026


South Rift Regional Office The Regional Manager

Industrial Area, General Mathenge Road

Within Pyrethrum Board Com-pound

P.O. Box 4507 - 20100 Nakuru, Kenya.

Tel: 254-051-2217544


Notes


TABLE OF CONTENTS

Foreword ………………………………………….... 4

Background ……..………………………………..... 5

Mandate ...……………………………………….…. 6

What is corruption ..…...……………..……………… 7

Corruption Risk Assessment and Corruption

Prevention Plan ...………………………………….. 8

Early Warning Signal of Corruption .………………. 9

Implementation of Corruption Prevention Plan ….. 10

Annex 1: Corruption Risk Assessment and

Corruption Prevention Plan ………………………... 12


FOREWORD The PCPB is continually implementing policies and programs to im-prove the social, political, economic, legal and institutional patterns and environment to create prosperity for Kenyans. It has committed itself to the realization of the principles of leadership and integrity as outlined in Chapter six of the Constitution of Kenya 2010. The Kenya government has also put in place legal and institutional structures e.g. the Anti-Corruption and Economic Crimes Act 2003, The Ethics and Anti Corruption Commission Act, 2011, Public Officers Ethics Act 2003, Public Procurement and Asset Disposal Act 2015 and Regulations 2006, Government Financial Management Act 2015, Leadership and Integrity Act 2012, United Nations Convention Against Corruption (UNCAC), African Union Convention on Preventing and Combating Corruption (AUCPCC), to address corruption. The government has been implementing the fight against corruption through the Public Service integrity program. Through this program, PCPB has trained seven integrity assurance officers who have been involved in the Corruption Risk Assessment, the preparation of the Corruption Prevention Plan, the Anti-Corruption Policy and the Code of Conduct and Ethics. In order for PCPB to play its role effectively, it must cleanse itself of corruption, wastefulness, negligence and inefficiency, and put in place strategies to mitigate against corruption. A corruption prevention com-mittee has been set-up with clear mandates on how to handle corrup-tion related cases or reports.

Chief Executive Officer/Secretary Pest Control Products Board


ACTIVITY

RESPONSI-BLE PER-

SON

BUDGET

TIME FRAM

E

MEANS OF MEASURE-MENT AND DELIVERY

Engage services of a qualified staff

Train/sensitize staff on proper stores records management.

Develop/Procure a computer-based stock control system

Adherence to estab-lished authorization procedures for stores

Enhance stores securi-ty.

Chief Execu-tive Officer

SCM Officer

Users

Annual Budgetary provision

Continu-ous

Regular sample stock takes

Annual stock take exercise

Stores docu-ments in place

Clean and se-cure store

Adherence to disposal guidelines

Members of the com-mittee be people of high integrity

Compliance with the provisions of the PPAD, 2015 and PPDR, 2006


SCM Officer

Users

- Continu-ous

Disposal sub-missions by users

Use of disposal plan

Disposal com-mittee and minutes of its meetings

Disposals as per procedures

Implement Annual Audit plan.

Conduct regular audits and advice manage-ment on areas of weak-nesses identified.

Adherence to code of conduct for auditors.


Internal Audi-tor

- Continu-ous


CORRUPTION PRONE AREA

CORRUPTION

RISKS

CORRUPTION PRE-VENTION STRATE-

GY

12 Stores Management Poorly maintained stock records.

Unqualified staff under-taking storekeeping tasks.

Lack of clear policy on stores management.

Failure to hold stores records securely.

Poor security of store items.

Establish a comprehen-sive stores records

Computerize stores rec-ords

Comply with guidelines on stores management

Comply with procedure for issues of stores

Have adequate security of stores.

13 Disposal of stores/assets

Conflict of interest.

Untimely or late disposal of stores.

Low valuation of stores.

Lack of objectivity in the determination of disposal criteria.

Leakage of information to potential bidders.

Comply with established guidelines on disposal of stores

Establish a Board of survey and disposal committee

Use PPAD, 2015 and PPDR, 2006

Confidentiality of delib-erations be maintained

(h) Internal Audit

1 Internal Audit func-tion

Failure to verify relevant records

Failure to conduct regu-lar checks on compliance to set rules and regula-tions

Failure to review proce-dures and policies.

Failure to report audit findings

Compliance with provi-sions of Public audit Act, Financial Management Act & International Au-dit standards.

Observance of Annual Audit Plans

Report true audit find-ings


BACKGROUND

The Pest Control Products Board (PCPB) is a Statutory Organization

of the Kenya Government established under the Pest Control Prod-

ucts Act, Cap 346, Laws of Kenya of 1982 to regulate the importation

and exportation, manufacture, distribution, disposal and use of pest

control products.

Presently, the Board operates under the following Subsidiary Legisla-tions (Regulations): The Pest Control Products (Registration) Regulations –

L.N.46/1984 & L.N.109/1984

The Pest Control Products (Licensing of Premises) Regula-

tions – L.N.145/1984

The Pest Control Products (Labeling, Advertising and Packag-

ing) Regulations – L.N.89/1984

The Pest Control Products (Importation and Exportations)

Regulations – L.N.146/1984

The Pest Control Products (Registration) (Amendment) Regu-

lations – L.N. 123/2006

The Pest Control Products (Licensing of Premises)

(Amendment) Regulations, 2006 - L.No. 124/2006

The Pest Control Products (Importation and Exportation)

(Amendment) Regulations – L.N. 125/2006

The Pest Control Products (Disposal) Regulations – L.N.

126/2006

The Pest Control Products (Labeling, Advertising and Packag-

ing) (Amendment) Regulations – L.No. 127/2006

The Pest Control Products (Licence Fees and Other Charges)


Regulations – L.No. 128/2006.

The Pest Control Products (Licence Fees and Other Charges) Reg-

ulations – L.No. 128/2006.

The Pest Control Products (Certificate of Registration) Regulation

2014. L.No. 7189/2014

The Pest Control Products (Registration) (Amendment) Registration

2014. L.No. 122/2014

The Pest Control Products (Registration) (Amendment) Regulations

2015. L.No.124/2015

MANDATE

The mandate of the Pest Control Products Board as prescribed in the Pest

Control Products Act and also in line with its vision and mission statement

includes the following activities:-

Investigating and prosecuting contravention of the Pest Control

Products Act.

Supervising the disposal of obsolete or undesired pest control prod-

ucts.

Advising the Minister on all matters relating to the Provisions of the

PCP Act and Regulations made there under.

Assessing the safety, efficacy, quality, merit and economic value of

pest control products with a view to registering them, if found suita-

ble.

Assessing suitability of premises used for manufacture/formulation,

re-packing, storage and distribution of pest control products for pur-

poses of licensing them for those functions.

Processing and issuing import/export permits to ensure that only

registered products are imported and in right quantities.


ACTIVITY

RESPONSI-BLE PER-

SON

BUDG-

ET

TIME FRAM

E


Evaluate as per the criteria set.

Facilitate training of Evaluation committee members.

Evaluate within the timeframe prescribed in the PPAD Act, 2015 & PPDR, 2006.

Interested parties to declare their interest and disqualify them-selves.


SCM Officer

Evaluation Committees

Annual budgetary provisions.

Continu-ous

Evaluation criteria within tender docu-ments

Evaluation reports using set criteria

Timely evalua-tion

Discipline staff who divert goods or receive lower quality products or services

Intensify stock verifica-tion.

Intensify audit inspec-tions.

Maintain register of assets.


SCM Officer

Inspection and Ac-ceptance Committee

User depart-ment/section

Finance de-partment

Annual budgetary provisions

Continu-ous

Acceptance and Inspection com-mittees

Acceptance forms duly signed

Register of assets

Authorization of pay-ments as per regula-tions.

Adhere to standard operating procedures for payments.


SCM Officer

Accountant


Continu-ous



CORRUPTION

RISKS


GY

9 Evaluation of quo-tations / tenders

Lack of an evaluation criteria.

Unqualified evaluation committee members.

Change of evaluation criteria.

Substitution of evaluation committee members.

Acceptance of unsolicited communications.

Delay in evaluation process.

Establish criteria for evaluation.

Train members of the evaluation committee.

Use evaluation commit-tees as per procurement guidelines.

Adhere to established evaluation criteria.

Involve experts in evalu-ation where necessary.

Comply with stipulated evaluation period.

10 Delivery and ac-ceptance of goods or service/ Perfor-mance of works

Receipt of substandard goods/services.

Substitution for lower quality goods or services.

Price variations and contract amendments.

Diversion of delivered goods for private use or resale.

Inspection and Ac-ceptance be undertaken as per threshold schedule.

Price variations and con-tract amendments be approved by the CEO.

Ensure complete delivery as per specifications.

11 Payment Payment for non-delivered goods/services.

Delayed payments.

Compliance with Gov-ernment Financial regula-tions.


Monitoring and ensuring adherence of quality standards of

pest control products from production to use.

Creating awareness of the general public on all aspects of

safety, storage, handling, disposal and use of pest control

products.

WHAT IS CORRUPTION? There is no single universal definition of the term corruption be-cause it is diverse with many manifestations. However, the Anti-corruption and Economic Crimes Act defines corruption as: -

An offence under any of the provisions of section 39 – 44, 46 and 47,

Bribery,

Fraud, Misappropriation of public funds, Abuse of office, Breach of trust, Dishonesty, Conduct of behavior where a person entrusted with public

or private responsibility or authority violates their duties for personal advantage or for the advantage of others, acts of omission or commission,

Omission resulting in personal advantage at personal ex-pense, abuse of office for gain to self or group to which one owes allegiance,

Dishonest use of ones legitimate power for personal gain, Extortion by those in position to offer free services to the

public for self-gain, Falsification, Soliciting or causing others to solicit rewards for otherwise

free service.


CORRUPTION RISK ASSESSMENT AND CORRUPTION PRE-VENTION PLAN Corruption Risk Assessment (CRA) is the systematic applica-tion of management policies, procedures and practices to the tasks of identifying, analyzing, evaluating, treating and monitoring corruption risk within the institution. It involves the identifica-tion of corruption loopholes in all functional areas of the organiza-tion and proposing mitigation measures, which when applied will seal the loopholes. This takes into account the real threats to cor-ruption as well as the perceived ones. Corruption Prevention Plan (CPP) can be defined as efforts and resources directed towards sealing loopholes that may allow corrupt practices. The plan outlines the strategies to be employed in sealing the corruption loopholes identified in the CRA. In addi-tion to the loopholes identified and the preferred strategy adopted for implementation in order to seal the loophole, the plan indicates the resources, actors and time frame. CRA and CPP are corruption prevention tools that enable man-agement in institutions to identify corruption prone functional are-as within the institution that may require special attention. It helps management to proactively avert the risk or threat of corruption occurring at the institution and makes it possible to stop corruption before it occurs. CRA and CPP also minimize exposure of staff to opportunities for corrupt practices. This will ultimately improve the image of the PCPB as well as enhancing transparency, efficiency and account-ability in its operations.


ACTIVITY

RESPONSI-

BLE PERSON

BUDGET

TIME FRAME


Publicize bids in ap-propriate media i.e. IFMIS ,newspapers, notice boards, PCPB website.

Have a fair quotation rotation method.

Ensure use of dispatch registers for quota-tions/tenders

Allow time as per the public procurement regulations

Let suppliers sign when collecting or receiving quotation or tenders

Discipline staff who leak information

Prompt response to request for clarifica-tions


SCM Officer

Heads of De-partments/Sections


Continu-ous

Dispatch regis-ter or email records

Rotation of bid invitation

Indication of response time and actual opening time

Have a quotation opening committee

Have quotation open-ing committee minutes

Have secure custody of bid documents be-fore and after evalua-tion

Discipline officers leaking information or substituting samples or brochures


SCM Officer

- Continu-ous

Timely open-ing as per regu-lations

Tender/quotation box

Tender/quotation open-ing minutes

Opening com-mittees



CORRUPTION RISKS

CORRUPTION PREVEN-

TION STRATEGY

7 Dispatch of tenders and quotation docu-ments

Insufficient notice for preparation of quotations / tenders

Leakage of information to preferred bidders.

Failure to answer requests for clarification sought by suppliers / contractors.

Comply with timelines pro-vided in the PPAD Act 2015 & PPD Regulations 2006.

Ensure uniformity of infor-mation released to prospective bidders.

Institutionalize procedures of dispatch of tender quotations.

8 Opening of bids, tenders / quotations

Delaying in opening.

Opening before time.

Leakage of bids infor-mation.

Substitution of docu-ments/ samples/brochures.

Different location for receiving bids and open-ing them.

Failure to provide secure storage of, and restricted access to, bids received.

Use tender/quotation boxes

Ensure centralized receiving of bids.

Open immediately after clos-ing

Have tender box keys kept by at least two senior officers

Invite users and suppliers/ contractors during opening

Have a quotation opening Committee


Annex 1 provides a detailed matrix of the CRA and CPP for the Pest Control Products Board showing:

Functional areas, Corruption prone areas, Corruption risks, Corruption prevention strategies, Activities, Responsible persons, Budgets, and Time lines.

EARLY WARNING SIGNALS OF CORRUPTION The Pest Control Products Board being a regulatory organi-zation offers services that are prone to corruption. The phe-nomena cited here below particularly when they exist simul-taneously indicate existence of corruption and other malprac-tices in the work systems. They indicate circumstances as to where the management should take a close look in order to identify loopholes for corrupt practices. The following corruption red flags may guide the manage-ment as indicators of corruption: -

Extravagant lifestyle Financial pressure Regularly staying late in the office for no apparent rea-

son Refusal or reluctance to accept a posting/transfer, even

with promotion Refusal or reluctance to take leave Inappropriate friendliness with juniors and clients Paying with cash – exceptionally fast or slow pay-

ments Frequent reports of loss of merchandise, or in the writ-

ing off of stock or bad debts.


Excessive purchase/heavy expenditure at discount or staff prices for items not required

Frequent and repeated purchases of small items from the same supplier

Irregular involvement in the affairs of other departments Over-willingness to work overtime during lunch time or take

on particular responsibilities Long inexplicable, hushed telephone calls Late reports and management information/documents pre-

sented for authorization in large, unrelated batches at busy times

Lost documents/documents presented in unusual format, photocopies instead of originals submitted

High staff turnover and low morale Excessive debts/liabilities (pecuniary embarrassment) Creating emergencies in order to buy Authorization or request for authorization late in the day or on

Friday or End of Financial Year. IMPLEMENTATION OF CORRUPTION PREVENTION PLAN (1) In order to implement the Corruption Prevention Plan, there is

hereby established a Pest Control Products Board Corruption Prevention Committee, hereinafter referred to as the committee’ with the following membership: -

Chairperson Chief Executive Officer/Secretary Members Heads of Departments Integrity Assurance Officers

(2) The committee shall have at least five (5) members and may

co-opt not more than three members. 3) The committee shall meet at least once every quarter.


ACTIVITY

RESPONSIBLE

PERSON

BUDGET

TIME

FRAME


Involve users.

Capacity building of users involved in specification prepa-rations.

Heads of Depart-ments/Sections

SCM Officer

Annual budget-ary provi-sion

Continu-ous

User requisitions with clear, con-cise and stand-ard technical specifications

Adhere to the thresh-olds and set guide-lines.

Chief Executive Officer

SCM Officer

Evaluation/Inspection & Acceptance Commitees

- Continu-ous

Use of methods within set thresholds

Issue standard pro-curement document to all bidders.

Discipline staff who release bid documen-tation.

Undertake local mar-ket survey.


SCM Officer


Annual Budg-etary provi-sion

Continu-ous

Use of standard tender docu-ments as guided by PPRA

Timely release of tender docu-ments to pro-spective bidders

Market surveys guided by the PPRA Market Index manual



CORRUPTION

RISKS


GY

4 Identification of needs / specifications

Tailoring of specifications and/or Terms of reference.

Weak technical specifi-cations that lead to wrong procurement.

Conduct periodic market surveys.

5 Choice of procure-ment method

Use of inappropriate procurement method.

Use procurement methods thresholds schedules as spelt out in the Public Procurement and Asset Disposal Act(PPAD) Act, 2015 & Public Procure-ment and Disposal Regu-lations (PPDR), 2006

6 Preparation of bid documents

Unnecessary complexity of bid documents.

Advance release of bid documentation or relevant information to preferred bidders.

Under or over-specifications requirements

Use of standard procure-ment document.

Confidentiality in prepa-ration of bid documents.

Use of clear/concise spec-ifications.


4) The committee shall have the following terms of reference:

Set priorities of prevention of corruption within PCPB

Ensure that all corruption prevention initia-tives are integrated within PCPB

Receive and review reports on corruption initiatives and recommend appropriate ac-tion

Plan and coordinate corruption prevention strategies

Consider and review internal training on corruption

Ensure all decisions and policies on cor-ruption prevention are communicated ef-fectively to all levels of staff and all inter-ested parties

Receive complaints and information of cor-rupt activities within PCPB and evaluate, analyze and recommend appropriate ac-tion

Monitor the impact of corruption preven-tion initiatives

Spearhead anti-corruption campaigns within areas of jurisdiction

Prepare and submit regular progress re-ports on implementation of the program and recommended actions on reported corrupt activities to the Ethics and Anti-Corruption Commission .



CORRUPTION

RISKS

CORRUPTION PREVEN-

TION STRATEGY

(a) REGISTRATION OF PEST CONTROL PRODUCTS1 Identification of prod-

ucts registration appli-cations for discussion by technical commit-tee

Selective/biased identifi-cation

Maintain an application register for complete applications

Use First In First Out (FIFO) method

2 Issuance/Extension of Imports/Exports per-mit

Delays in processing.

Selective approvals.

Failure and delay to communicate deficien-cies in application to the applicant.

Forged signature and stamp

Maintain an imports/export permits register.

Use First In First Out (FIFO) method to process permits.

Automate processing of im-ports/exports permits.

Incorporate permit extension in the Kentrade System.

3 Allocation of products applications for regis-tration

Selective allocation of applications.

Random allocation.

4 Issuance of efficacy trial permits for new products applications

Issuance of trial permits for deficient applications.

Trials being conducted without a permit

Maintain records of processing and approvals of trial permits.

Follow registration guidelines.

5 Evaluation of efficacy trials in the field, Physical chemical studies, toxicology and other studies

Unsafe products, or non efficacious products being passed.

Efficacious products being failed.

Comply with accreditation crite-ria.

Use an institutionalized evalua-tion criteria for monitoring and evaluation.

6 Evaluation of dossiers Biased reporting of an evaluation.

Lack of a comprehensive evaluation of dossier.

Team evaluation of dossier.

Peer review of evaluation re-ports.

Annex 1: CORRUPTION RISK ASSESSMENT AND CORRUPTION PREVENTION PLAN


ACTIVITY

RESPONSI-BLE PER-

SON

BUDGET

TIME

FRAME

MEANS OF

MEASUREMENT AND DELIVERY

(g) PROCUREMENT OF GOODS AND SERVICES

Facilitate staff to attend procurement-based trainings.

Finalize and ap-prove procurement polices and sensitize staff.

Adhere to guidelines on Records management.

Procure and implement computer-based procurement systems.


Supply Chain Management (SCM) Of-ficer

Evaluation/Inspection & Acceptance Commitees

Annual Budgetary provision/Procure-

ment plan

Continu-ous

Training certificates

Budget and Initiatives to computerize

Use procurement plan.

Adhere to budget-ary provisions.


SCM Officer

Heads of Departments/Sections


Annual

Approved Annual Procurement plans

Annual disposal plan

Evaluate suppliers of goods and ser-vices as per set criteria.

Regular consulta-tion with the Na-tional Treasury on procurement issues.


Heads of Departments/Sections

SCM Officer

Annual budgetary provision

Continu-ous

Prequalified list

Evaluation reports



CORRUPTION

RISKS

CORRUPTION PRE-

VENTION STRATEGY

(g) PROCUREMENT OF GOODS AND SERVICES1 Administration of

procurement func-tion

Ignorance in pro-curement law and regulations.

Poor record keeping of procurement processes.

Retrospective Ratifications of approvals.

Manual procurement process.

Have approved internal pro-curement policies.

Sensitize staff on procure-ment laws and regulations.

Comply with PPRA record keeping manual.

Procurements be undertaken as per PPAD Act, 2015 & PPD Regulations, 2006.

Computerize procurement activities.

2 Procurement plan-ning

Failure to adhere to Procurement plan.

Procuring without a budget.

Adhere to annual procure-ment plans

Comply with PPRAguide-lines on procurement budg-ets.

3 Registration / prequalification for complex and spe-cialized goods, works and services contractors/suppliers

Disqualification of potential suppliers/ contractors.

Registration of un-qualified suppliers e.g. brief case sup-pliers.

Comply with criteria set for registration/pre-qualification.

Involve users and respective committee in the evaluation process.

Conduct due diligence of the suppliers/ contractors.


ACTIVITY

RESPONSI-BLE PER-

SON

BUDG

ET

TIME

FRAME

MEANS OF MEASUR-MENT AND DELIVERY

(a) REGISTRATION OF PEST CONTROL PRODUCTS For complete applica-

tions, process according to the order in the regis-ter

Head of Reg-istration & Analysis de-partment

Annual Budget-ary pro-vision

Continuous Number of dossiers re-ceived in FIFO register

Ensure updated imports/export permit register

Prompt communication of deficiencies to appli-cants

Maintain operational Kentrade System

Liaison with Kentrade

Registration Officers

Inspectors

Accountant


ICT Officer

Clerical Of-ficers

- Continuous Number of imports/export in the register

Number of rejected import application

Electronic per-mits extension

Use systematic random allocation process.

Registration clerk

- Continuous Number of products allo-cated using the criteria

Strict adherence to regis-tration guidelines before issuance of permit.


- Continuous Number of permits without deficiencies

Number of trials with per-mits

Impromptu visits to trial sites by registration of-ficers.

Follow trial protocols.

Accreditation of trial institutions.


Incorpo-rate in Annual budgets

Continuous Number of non efficacious products

Number of efficacious products failed

Each dossier be evaluat-ed by a relevant expert.

Introduce peer review.


- Continuous Number of dossiers evalu-ated

Annex 1: CORRUPTION RISK ASSESSMENT AND CORRUPTION PREVENTION PLAN



CORRUPTION RISKS

CORRUPTION PREVEN-TION STRATEGY

7 Sampling of pesticides(Post Registration surveil-lance)

Selective/biased sampling of pesti-cides

Apply sampling protocols.

8 Analysis of product sam-ples

Biased reporting/Pre-determined results.

Delays in sample analysis.

Inter-changing sam-ples.

Maintain a register of samples sub-mitted.

Use the FIFO method.

Confirmatory analysis.

Proper custody of samples.

9 Communication of deci-sion of the Board on reg-istration of products

Selective communi-cation

Delays in communi-cation

Prompt communication

10 De-registration/ Revoca-tion of registration of products

Raising of false alarms

Follow de-registration regulations

Establish Revocation/de-registration procedures

11 Registration of products Adhoc requirements for registration

Conflict of interest

Follow products registration regu-lations

Establish procedures for introduc-tion of new requirements

Board/committee members/registration officers to declare in-terest

Secure dossiers and Confidential Business Information (CBI)


ACTIVITY

RESPONSIBLE

PERSON

BUDGET

TIME

FRAME


Maintain independence of auditing functions


Internal Auditor

- Annual budget pro-

vision

Continuous Audit reports

Adherence to the Fi-nancial Management Act.


Accountant

- Continuous Investments reports

Adherence to the rec-ommendations of the budgeting committee.


Heads of Depart-ments/sections

- Continuous Approved budgets

(f) INFORMATION COMMUNICATION TECHNOLOGY SERVICES

Adhere to established procedures.

Prompt update of rec-ords as authorized.

Maintain system logs and audit trails.

Implement information security measures.

Installation of physical security gadgets in computer rooms, lock-able cabinets, firewalls.

Heads of Depart-ments

Information Com-munication Tech-nology Officers


Continuous Issuing of user rights to em-ployees with different levels of access rights.

Scheduled maintenance of software and peripheral devices.

Constant mon-itoring of system logs

Regular update of anti-virus license.

Adhere to ICT mainte-nance schedules.

Establishing offsite back-ups.

Heads of Depart-ments

Information Com-munication Tech-nology Officers


Continuous Hardware and software maintenance.

Software up-grades and configurations.



CORRUPTION RISKS

CORRUPTION PREVEN-

TION STRATEGY

4 Internal audit function

Non disclosure of true audit findings

Strengthen internal auditing unit

5 Financial invest-ments

Inappropriate investment. Comply with provisions of the Financial Management Act.

6 Budgeting process and funds re-allocation

Failure to involve user departments in the budget making process

Allocation of funds with vested interests.

Involvement of budget com-mittee in budgeting process.

(f) INFORMATION COMMUNICATION TECHNOLOGY SERVICES1 Information Secu-

rity Unauthorized access to

information.

Loss/misuse of data or information.

Unauthorized amend-ments (Addition/deletion/insertion) of information

Failure to update records as authorized

Issuance of access code to unauthorized users

Use access controls to systems e.g. usernames and passwords.

Monitoring system usage in the system logs and audit trail.

Utilize procedures for amend-ments of electronic records.

Adhere to ICT policy

Comply with approved user authorization/access privileges.

2 Hardware and Software manage-ment

Introduction of malicious program.

Disruption of office ac-tivities.

Delay of updating/upgrading management systems.

Virus protection.

Utilize ICT systems mainte-nance schedules.

Develop Business Continuity/Disaster Recovery Plans.


ACTIVITY RESPONSIBLE PERSON

BUDGET TIME FRAME

MEANS OF MEASUREMENT AND DELIVERY

Develop of sampling protocols by analysts

Sampling to be con-ducted by inspectors as per the PCP Act.

Adherence to sampling protocols by inspectors.

Pesticide analysts.

Inspectors.

- Continu-ous

Number of proto-cols

Update register of pes-ticide samples.

Submission of full analytical report.

Undertake confirmato-ry tests by a different officer.

Establish multi-lock access system for sam-ples.

Pesticide Analysts Incorporate in Annual budgets.

Continu-ous

Updated register

Number of confir-mation tests

Comply with provi-sions in the service delivery charter.


- Continu-ous

Compliance with service charter

Adhere to regulations on de-registration of products

Follow the laid down procedure


- Continu-ous

No of false alarms

Apply registration re-quirements uniformly.

Interested members to disqualify themselves from decision making process.

Store information in lockable cabinets or bulk filers

Board of Manage-ment.

Technical and Registration Com-mittee.

Chief Executive Officer.

Registration Offic-ers

- Continu-ous

Number of guide-lines

Use of SOPs

Use of lockable cabinets/bulk filers


(b) INSPECTION AND LICENSING OF PREMISES CORRUPTION

PRONE AREA CORRUPTION

RISKS CORRUPTION PREVEN-

TION STRATEGY

1 Issuance of premis-es/business licenses

Issuance of licenses to non-complying premises.

Delays in issuance of licenses.

Issuance of licenses to uninspected prem-ises

Compliance with established minimum requirements criteria.

Follow provisions in the service charter.

2 Inspection of prem-ises/businesses

Biased/selection of premises / regions to inspect

Develop an Annual work plan

Rotational program for officers

3 Inspection report Falsification of report Ensure inspectors are of high integrity

Random verification checks

4 Investigations Selective investiga-tion.

Inconclusive investi-gations.

False allegations.

Delays in investiga-tions.

Leakage of infor-mation leading to interference with evidence.

Abuse of discretion in disposal of cases of non-compliance.

Maintain an Occurrence Book (OB).

Train inspectors on investiga-tions.

Verify source of information

Restrict investigation infor-mation

Hold Inspector’s meeting to adjudicate in cases of non-compliance in accordance to the law


ACTIVITY

RESPONSIBLE

PERSON

BUDGET

TIME

FRAME


MANAGEMENT Keep track of all the

receipt books Accountant

Internal Auditor

Annual budg-et provision

Continuous Upadated register of receipt books issuance

Carry out regular reconciliation of cash book

Regular auditing to be undertaken

Accountant

Internal Auditor

- Continuous Monthly bank recon-ciliations

Audit reports

Ensure all collected revenue is banked by end of week

Accountant

Internal Auditor


Continuous Receipt vouchers

Observe checks and balances in the ap-proval process.

Adherence to govern-ment financial regula-tions.


Accountant

Internal Auditor

Inspectors

- Annual budget provi-

sion

Continuous Budgetary levels

Procurement plan

Regular auditing of accounting records

Accountant

Internal Auditor


-

Continuous Audit reports

Adherence to guide-lines on acquisition and disposal of assets


Accountant

Procurement of-ficer

Internal Audit


-

Continuous Up to date Asset register



CORRUPTION RISKS

CORRUPTION PREVEN-

TION STRATEGY

(e) FINANCIAL 1 Revenue manage-

ment (receipting and deposits)

Failure to maintain an ac-countable receipt books reg-ister.

Failure to keep track of reve-nue collections and banking.

Teaming and lading.

Unreconciled cash records.

Maintain receipt books regis-ter.

Internal controls and supervi-sion.

Comply with requirements for banking of cash collec-tions.

2 Expenditure man-agement

Making unauthorized pay-ments from revenue collect-ed.

Unauthorized lending.

Non-compliance with limits for cash payments.

Unauthorized payments.

Failure to make authorized payments.

Apply internal controls.

Compliance with Expenditure guidelines.

3 Accounting rec-ords management

Falsification of expenditure documents.

Non-traceability of financial records.

Wrong posting of accounts

Observe internal controls

Periodic tracking of budget-ary allocation and expenditure

4 Assets Manage-ment

Inappropriate acquisition and disposal of assets.

Comply with guidelines on acquisition and disposal of assets


(b) INSPECTION AND LICENSING OF PREMISES ACTIVITY RESPONSIBLE

PERSON BUDGET TIME

FRAME MEANS OF MEAS-

UREMENT AND DE-LIVERY

Adhere to the estab-lished minimum cri-teria.

Prompt issuance of licenses upon inspec-tion and payment of relevant fees

HOD and Region-al Managers

- Continuous Inspection reports

Target 0- 2 weeks for license issu-ance upon inspec-tion and payment of licence fees

Adhere to the work plan



Continuous Work programmes and reports

Inspection be carried out by at least two officers


- Continuous All work programs and reports

Record outcome of every stage of inves-tigation in the OB.

Facilitate training of inspectors.

Inspectors to collect preliminary infor-mation prior to travel.

Disciplinary measures be taken against officers who leak information

Investigating officer to be involved at all stages in the disposal of cases.


Incorporate in the

Annual budget

Continuous Investigation file and report

Number of inspec-tors trained

Investigation pro-grams and reports

Number of case and action taken

Investigation report



CORRUPTION RISKS


GY

5 Categorization of Busi-nesses/premises and Col-lection of license fees

Failure to collect required fees as per category of busi-ness.

Computerization of prem-ises details.

Ensure inspectors are people of high integrity.

6 Impounding/seizure and release of products

Selective impounding/release of products.

Comply with minimum criteria for seizure/release of products.

7 Prosecutions Selective institution of legal action.

Failure to follow court pro-ceedings to conclusion.

Comply with PCP Act.

Follow-up cases to logical conclusion.

8 Training of stakeholders Biased selection of officers to undertake training of stake-holders.

Have a work plan on trainings.

9 Verification and release of pesticide imports/exports at ports of entry/exit

Allow importation/Exportation of products with-out import/export permit.

Release of illegally imported products.

Irregular release of products.

Apply procedures of re-lease.

Engagement in pesticides business

Conflict of interest Adherence to Cap 346


ACTIVITY

RESPONSIBLE

PERSON

BUDG-

ET

TIME

FRAME


(d) ADMINISTRATION SERVICES

Control of issuance of work tickets

Scrutinize details of journey before authoriz-ing use or fueling

Use of fuel cards.

Adherence to service schedules and repair guidelines

Carry out market survey to determine costs of repairs and maintenance

Use laid down procure-ment procedures to seek repairs and maintenance services

Prompt payments after ascertaining that the job has been done as re-quired.

Monthly fuel analysis reports.


Administrator

Accountant

Transport officer

Annual budget-ary pro-vision

Con-tinuou

s

Procurement of a fleet manage-ment system

Observe ethical commu-nication practices pre-scribed in the code of conduct and ethics

Adhere to the PCPB core values

Adherence to official language when com-municating official mat-ters

All PCPB offic-ers

- Con-tinuou

s

Work environ-ment surveys


CORRUP-

TION PRONE AREA

CORRUPTION RISKS

CORRUPTION PREVEN-

TION STRATEGY

(d) ADMINISTRATION SERVICES

Transport Misuse of motor vehicles.

Falsification of fueling records.

Exaggerated costs of re-pairs and maintenance.

Delays in carrying out repairs and maintenance of vehicles.

Repair and maintenance of vehicles being done by unauthorized garages.

Delayed payments after repairs have been done.

Maintenance of records for work tickets.

Authorization procedures for use and fueling of vehicles

Use of service schedules and repair guidelines.

Use of procurement committee to secure repair and mainte-nance services for vehicles.

Use of authorized garages for repairs and maintenance.

Expeditious processing of pay-ments.

2 Internal Commu-nication

Use of intimidating lan-guage.

Lack of feedback.

Use of unofficial language in communicating official matters

Implementation of the code of conduct and ethics for PCPB

Institutionalize PCPB core val-ues

Use of official language of communication


ACTIVITY

RESPONSIBLE

PERSON

BUDGET

TIM

E FRAME


Operationalize the PCPB computer-based database system..

Train officers on in-tegrity issues.


Inspectors

Accountant

ICT officer


Con-tinuou

s

Data inputted into PCPB com-puter based sys-tem

Bank slips Number of officers trained; Discipli-nary cases report-ed and acted upon

Apply minimum crite-ria uniformly


Inspectors

- Con-tinuou

s

Inspection re-ports

Consistent adherence to the PCP Act.

Supervision be under-taken to ensure cases are taken to full com-pletion


Inspectors


Con-tinuou

s

All cases of non compliance in-vestigated

Cases followed to logical conclu-sion

Allocate officers on rotational basis

Adherence to work plan on trainings.


Inspectors

Registration Of-ficers


Con-tinuou

s

Training plan

Number of offic-ers trained

Verification to be done by one officer on a rotational basis.

Only authorized offic-ers to release prod-ucts.

Inspectors Annual budgetary provision

Con-tinuou

s

Work plans for port activities

Monthly reports

Signing the code of conduct and ethics for PCPB officers

Signed Code of conduct and ethics by all inspectors

CEO

HR

Head of compli-ance and enforce-ment.

- Con-tinuou

s


CORRUP-TION

PRONE AR-EA

CORRUPTION RISKS


GY

(c) HUMAN RESOURCE MANAGEMENT

1 Human re-source planning

Adhoc employment due to non-adherence to em-ployment guidelines.

Incorporate Human Re-source Planning within PCPB plans.

2 Recruitment / Selection

Favouritism

Tribalism

Nepotism

Cronism

Interested parties being involved at the selection stage

Failure to advertise or limiting circulation of advert

Job analysis

Advertisement

Interview panels

Development of succes-sion plan


ACTIVITY

RESPONSIBLE PERSON

BUDG-ET

TIME FRAME


Manage discipline cases through a disci-plinary committee


Human Resource Officer Chief Executive Of-ficer -

Continu-ous

Minutes of Staff Advisory Com-mittee

Adherence to the code of conduct and ethics

Reference to code of conduct

Adhere to disciplinary procedures

Allow for appeal/redress

Number of appeal cases

Adhere to the provi-sions of Career Guide-lines and Human Re-source Manual


Human Resource Officer

- Continu-ous

Compliance to pay structures

Rewards to be based purely on fairness and merit

Adoption of public service reward and sanction policies

Use of a Com-mittee to handle reward

Adhere to Retirements Benefits rules and reg-ulations.

Implement a human resource management system.

Prompt processing of exit benefits.



- Continu-ous

Prompt pro-cessing of exit benefits

Conduct appraisals Objectively.

Consultation between appraiser and appraise on agreed targets.

Provide feedback on staff appraisals.




- Continu-ous

List of apprais-al reports every end of year


CORRUP-TION PRONE AREA

CORRUPTION RISKS


6

Discipline Violation of laid down procedures in handling cases.

Deliberate delays in con-cluding cases.

Set up disciplinary committees

Comply with code of conduct and ethics

Comply with disciplinary proce-dures

7 Reward manage-ment and staff motivation

Disparities in pay struc-tures and benefits.

Discrimination and injus-tices in rewarding of bene-fits.

Compliance with Career Guide-lines and Human Resource Man-ual

Establish an adhoc reward com-mittee

8 Management of Separation (Exit)

Delays in payment of bene-fits.

Compliance with Retirements Benefits rules and regulations.

Computerize employee records.

9 Performance management

Using appraisals to settle scores.

Rewarding and promoting non-performers

Subjective appraisal due to failure to set or agree on standards and targets .

Compliance to set appraisal Guidelines.

Use of negotiation in setting individual performance targets.


ACTIVITY

RESPONSI-BLE PERSON

BUDGET

(Kshs)

TIME

FRAME


(c) HUMAN RESOURCE MANAGEMENT

Carry out job evaluation to determine staff require-ments.

Adhere to employment guidelines


Human Re-source Officer

2.5M Once every four years

Con-tinuo

us

Job evaluation carried out

Job description to be as stipulated in the Career Guidelines



- Con-tinuo

us

Job Descriptions issued to all employees

Place job advertisement for a period of at least 21 days in widely circulated media and PCPB website



Incor-porate in an-nual

budget

Con-tinuo

us

Number of ad-vertisements placed in print media and web-site

Manage recruitment and selection through commit-tees

Members of the commit-tee be people of high in-tegrity and from relevant functional areas

Adherence to selection requirements

Have pre-determined criteria for short listing

Conduct interview using objective methods



- Con-tinuo

us

Constituted shortlisting and interview panels and interview criteria as per requirements

Timely replacement of exiting staff subject to budgetary provisions.

Integrate succession plans within PCPB staff devel-opment plans



Head of Depart-ment’s

- Con-tinuo

us

Human resource plan


CORRUP-TION PRONE AREA

CORRUPTION RISKS


3 Managing career progression

Arbitrary/Selective promotions due to non-adherence to Career Guidelines

Failure to facilitate staff to acquire requi-site requirements for career progression leading to low morale.

Decision Making through Staff Advisory Committee

Use Career Guidelines in De-cision Making.

Adherence to human resource Manual

4 Placement, de-ployment and transfers

Placing employees in areas they are not qual-ified for.

Transferring/deploying employees for personal interest or punitive measures.

Compliance to staff rules and regulations on transfers and deployment.

Placement of employees be based on Career Guidelines.

Compliance to set guidelines on length of stay in stations.

5 Training and de-velopment

Favouritism.

Tribalism.

Nepotism.

Cronism.

Adhoc identification of persons to attend train-ing.

Denying opportunities to deserving employ-ees.

Undertake Training Needs Assessment (TNA).

Develop Training Guidelines/Policy.


ACTIVITY

RESPONSI-BLE PERSON

BUDGET

TIME FRAME


Adherence to rec-ommendations of Staff Advisory Committee


Human Re-source Officer Chief Executive Officer


Con-tinuous

Minutes of Staff Advisory Com-mittee meetings

Adherence to estab-lished schemes of service

Periodic review of career guidelines

Reference made to career guide-lines in every decision

Integrate and adhere to the established human resource manual

Reference made to HR Manual .

Adherence to the set guidelines on trans-fers and deploy-ments

Placement to be done based on area of expertise



Heads of De-partments

- Con-

tinuous

Transfers and deployment of staff done as per guidelines

Managing training selection processes through committees.

Preparation and adherence to train-ing projections.

Training on need basis upon under-taking TNAs.

Adherence to rec-ommendations of Staff Advisory committee.



- Con-

tinuous

Training pro-gramme as per Staff Advisory Committee ap-proval.

Documents

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